Comparative paper on USA, Canada & UK FOI

Recently published by UCL's Consitution Unit:

"Freedom Of Information: History, Experience And Records And Information Management Implications In The USA, Canada And The United Kingdom"

"This paper, prepared by the Unit for the ARMA International Educational Foundation, explores freedom of information in practice in Canada, the United Kingdom and the United States. Highlights include comparative sections on use of exemptions, practical issues for authorities and points relevant to records managers, as well as national case studies on media use of FOI in the UK and use of the National Security Exemption in the US since 9/11."

download the paper from the ARMA website.